Background
Luther Midelfort Bed Tower Expansion will provide additional hospital beds at
the Luther Midelfort Campus. Since this is an addition to an existing
hospital, construction activities must also be planned to minimize disruption
to patients and visitors. This $80,000,000 expansion project will incorporate
the use of two tower cranes during the construction process.
- Identification of Partners
The following groups will participate in the partnership:
- Occupational Safety and Health Administration (OSHA), Eau Claire,
Wisconsin Area Office
- The Boldt Company
- J.F. Ahern Co.
- Hunt Electric Company
- Wisconsin Safety and Health Consultation Program (WisCon)
- Purpose/Scope
The purpose of this Partnership is to reduce injuries, illnesses and
fatalities during the construction of the Luther Midelfort Bed Tower
Expansion. The project will take two years to complete. It is anticipated
that, at its peak, the project will employ a total of 250 tradespersons
onsite and involve more than 20 subcontractors. All Partners have important
safety roles at the Project as identified in this Partnership. A
comprehensive Project Specific Risk Control Plan has been implemented and
addresses the respective safety roles of all employers and employees at the
Project.
This Partnership provides a unique opportunity to closely review the
operations of tower cranes, and develop a model training program that can be
used for outreach. Additionally, The Boldt Company is in the process of
submitting a Voluntary Protection Program (VPP) application. The Partnership
will help The Boldt Company apply for VPP by reviewing its program compared
to VPP criteria.
- Goals/Strategies
Goal No.1: Maintain an injury and illness rate at a minimum of 50% below the
most recent national and Wisconsin averages for general construction. The
actual target number will be established through information provided by the
Bureau of Labor Statistics’ (BLS) Total Case Incident Rate (TCIR), Days
Away, Restricted and Transferred (DART), and Days Away From Work Injury and
Illness (DAFWII) rates.
Strategy:
- Injuries, illnesses, and fatalities will be minimized by implementing
an effective, comprehensive site-safety and health program.
- Identify hazards and take immediate corrective action.
- Contractors will conduct daily safety inspections.
- Contractors and Site Safety Representatives (SSR)/Managers from The
Boldt Company will conduct joint safety inspections weekly.
- Monthly comprehensive inspection by Partners will be conducted.
- Interview employees as part of the inspection process.
- The project will utilize construction industry “Best Management
Practices” to be compliant with OSHA fall protection rules.
(Although providing mandatory fall protection at the 6’ level is not
required for all fall hazards by the current OSHA construction standards
and is not mandated by OSHA as a requirement for participation in any
OSHA partnership agreement, the contractors on this partnership are
committed to providing a greater level of protection to the employees
working at this site and will require protection at the 6’ level and
above.)
- Implement a Drug and Alcohol Program that includes random drug
testing, “just cause” testing, and post accident drug testing for
employees working at the construction site.
- Develop and implement an Emergency and Accountability Plan to
provide immediate response to accidents, incidents and severe weather
for the project site.
- Require that excavation permits be in place prior to any soil
penetrations.
- Require Hot Work Permits when necessary.
- Implement a hazard recognition and near-miss programs for project.
- Implement a lock out/tag out and confined space program.
- Contractors will utilize ground fault circuit interrupters (GFCI) at
all times.
- Struck-by injury prevention – Loads shall not be lifted directly
over the heads of workers. All workers shall wear high-visibility
clothing when working at ground level outside of enclosed buildings
where it does not impose additional hazards. Examples of additional
hazards may include but not be limited to welding and/or working around
rotating equipment where an entanglement hazard exits.
- Implement a “Safety Task Analysis” (STA) program.
- Require that all equipment (cranes, forklifts, aerial lifts,
scrapers, vehicles, bobcats, etc.) be inspected upon arrival at the site
and prior to daily use.
- Wisconsin Safety and Health Consultation Program (WisCon) will be
requested to assess and address onsite Industrial Hygiene
issues/problems as needed.
- Contractor will be compliant with Luther Midelfort security
procedures and programs.
Goal No. 2: All contractors will have effective written safety and
health programs
Strategy:
- Develop, distribute, implement and maintain a site-specific
comprehensive safety and health plan.
- Contractors who do not have their own safety and health program must
adopt “Boldt’s Plan” or utilize the services of either the WisCon or the
insurance company to help them develop a site-specific plan.
- All primes and designated subcontractors will designate an onsite
Safety Representative/competent person.
Goal No.3: Improve/Increase the level of safety and health training:
- Site-Safety Representatives (contractors) will have completed or
will complete the OSHA 30-Hour construction course or equivalent.
- Supervisory personnel will complete an OSHA 10-Hour construction
course. (Subcontractors can show a valid certification card).
- At least 50 % of the construction workers will have completed the
OSHA 10-Hour construction course.
- All contractors will receive a site-specific Risk Control Plan,
and each employee will complete the New Employee site-specific safety
orientation.
- Provide hazard-specific training as necessary.
- Develop a tower crane training course that can be used as outreach
for training others.
- Implement a procedure and process to have operators CCO-certified
for tower cranes
Strategy:
- Conduct training as needed.
Goal No. 4: Link the Partnership to the VPP
- This Partnership will be a stepping stone for The Boldt Company to
submit a VPP application.
Strategy:
- Safety and health programs will be evaluated against the VPP criteria.
- A “VPP Onsite Evaluation” will be conducted for this worksite. That
evaluation will be counted as one of the sites needed for approval when
the VPP application is submitted.
- Performance Measures
- Collect the following injury and illness data and compare the
incidence rates to the national average and Wisconsin average:
- TCIR – Total Case Incidence Rate
- DART – Days Away, Restricted and Transferred incidence rate
- DAFWII – Days Away From Work Injury and Illness rate
- The number of hazard recognition and near-miss incidents identified.
- The number of disciplinary actions taken and recorded.
- Collect the number of contractors who:
- Have their own safety and health program.
- Adopt The Boldt Company’s safety program.
- Receive assistance from WisCon with onsite consultation and/or
receive assistance developing a safety and health program.
- Receive assistance from the insurance company to develop a safety
and health program.
- Improve their safety and health program as a result of this
Partnership.
- Collect the number of number of employees trained in:
- OSHA 10-Hour and OSHA 10-Hour +;
- OSHA 30-Hour;
- Site-specific orientation training; and
- Hazard-specific training.
- Annual Evaluation
The Annual Evaluation, as described in Appendix C of Directive CSP
03-02-002, will be completed by OSHA with input received from other
partners. The Boldt Company’s Safety Manager will collect and maintain the
following data specified in the measurement factors:
- Injury and illness information.
- A record of training conducted relative to the measurement factors
(including the number of employees trained). The training may have been
conducted by the The Boldt Company or others (State Consultation, Labor
Unions, OSHA, and contractors).
- Copies of the prime contractor’s safety and health program plans, as
well as names of designated Site-Safety Representatives.
- Number of contractors who adopted the Boldt Risk Control program.
- Number of contractors referred to WisCon or the insurance company for
assistance in developing their own safety and health programs.
The WisCon program managers will report the number of consultations
conducted at this worksite and the number of contractors that developed or
improved their safety and health programs through consultation.
- Benefits
OSHA Non-Enforcement benefits:
Outreach, technical assistance and training will be available to OSP
participants. Examples include:
- Priority consideration for free onsite OSHA-funded safety and health
consultation.
- OSHA and OSHA Consultation personnel may be available for a variety of
onsite/offsite activities such safety and health management system
reviews, guidance in conducting workplace audits and evaluations, and
training assistance.
- Providing informational material such as safety and health brochures,
pamphlets and electronic tools.
OSHA Enforcement Benefits:
- An additional 10% reduction for good faith beyond reductions provided
for in the FIRM when calculating initial penalties. Maximum good faith
would be 35%.
- The Area Director, under the authority delegated by the Regional
Administrator (RA), has the authority to negotiate the amount of penalty
reduction as part of an informal settlement agreement.
- OSHA Verification
Onsite Non-enforcement Verification:
Onsite non-enforcement verification reviews will be conducted as part of the
monthly Partnership meeting. At this time, the partners will be divided into
groups and assigned a portion of the project to inspect. OSHA will accompany
one of these inspection groups. A union representative can choose to be part
of the OSHA inspection group. OSHA will make a referral for an enforcement
inspection if management refuses to correct a serious hazard identified
during the non-enforcement verification visit.
Onsite Enforcement Inspections:
One unannounced OSHA focused enforcement inspection will be conducted
annually. These inspections include the potential for issuing citations and
assessing penalties for violations. Enforcement inspections may be combined
with other unprogrammed inspections, for example, a complaint inspection.
- OSP Management and Operation
Each partner will designate at least one representative to the monthly
Partnership meeting.
The partners will discuss safety data such as hazards, as well as trends and
corrective actions taken.
The following data/information will be provided for OSHA’s review at the
monthly meetings (this information will be updated monthly).
- Total number of OSHA recordable injuries and illnesses, number of lost
and restricted workday cases.
- Accident investigations and WC-12 forms. Only the WC-12 reports from
the start of the project to present need to be provided for the initial
meeting.
- First aid log.
- Hazard Recognition and Near-Miss log.
- Hours worked (total for all contractors and hours for The Boldt
Company).
- Findings of safety audits and corrective actions taken.
- Safety trends.
- Disciplinary actions taken.
- Number of employees trained by targeted category.
- Copies of contractor’s safety and health programs available for
review.
The Boldt Company will:
- Manage the safety and health of the construction project.
- Implement and maintain a site-specific, comprehensive safety and
health plan. The plan will be written and distributed to site contractors.
- Assign an experienced Safety Manager
- Oversee safety and health for the entire construction site, enforce
safety and health rules and regulations, and have the contractual
obligation to stop and correct all unsafe conditions and acts. Actions
taken to address in-compliance with the site’s safety and health plan will
be in accordance with contractual agreements.
- Conduct safety inspections of designated areas within the project
construction site utilizing WisCon, insurance carriers, and Contractor
Safety Representatives, as well as employee involvement.
- Implement the following training provisions of the safety & health
programs.
- Provide on-going safety training:
- Provide the OSHA 10-Hour or OSHA 30-Hour construction safety and
health course for supervisory personnel of the participating contractors.
- Provide New-Hire safety orientation training for all employees prior
to work.
- The Boldt Company’s Safety Manager will be responsible to:
- Facilitate Contractor Safety Team meetings.
- Investigate events with contractor representatives.
- Publish “Safety Alerts/Toolbox Talks” to communicate safety issues
to site employees.
- Utilize “Safety Task Analysis” to track safety trends, and will report
on the trends at monthly Partnership meetings.
- Audit the required OSHA logs of injuries and illnesses for all
contractors at the site.
- Maintain a record of all safety and health-related inspections with
documented corrective actions.
- Provide OSHA with requested data and information.
All Contractors will:
- Perform safety and health responsibilities as provided by contract or
as stated in the Partnership.
- Submit a safety and health plan to The Boldt Company prior to
beginning work or adopt the site-specific risk control plan.
- Designate a Site-Safety Representative.
- Conduct daily inspections, participate in weekly and monthly jobsite
inspections.
- Utilize WisCon for consultation inspections and industrial hygiene
services.
- Address all hazards immediately which are identified during
walkthrough audits of the site. WisCon will conduct follow-ups as
appropriate.
- All contractors will fully participate in the monitoring activity
and will allow their employees to be monitored (WisCon will be
conducting industrial hygiene monitoring). Any overexposures found will
be addressed following the standard OSHA consultation procedures.
- OSHA and WisCon will be informed of any unusual work activity
planned for the site well in advance. Unusual work activity includes,
but is not limited to, explosive blasting, helicopter operations,
underwater operations, and critical lifts.
Prime and Designated Contractors will:
- Designate an onsite Safety Representative to be the liaison to the
Boldt Company’s Safety Manager.
- Assign a Safety Representative (or a designate) to attend the monthly
Contractor Safety Team meetings, and will provide a means of distributing
information to employees.
- Conduct and document onsite safety inspections, review trends at the
contractor monthly Safety Team Meetings, and suggest potential corrective
actions.
- Require designated Safety Representatives to address safety issues and
hazards for their employees and to any subcontractors who may report to
them.
- Require designated contractor Safety Representatives to accompany the
jobsite Safety Manager on jobsite inspections of their respective work
areas.
- Ensure that OSHA-required training is completed and documented.
- Ensure that assigned personnel responsible for safety topics at the
weekly contractor coordination meeting complete the requirement.
- Will designate representatives to the onsite Labor/Management Safety
Team (when it is formed), and support the representative’s involvement in
team activities.
Wisconsin Safety Consultation-WiSCon will:
- Participate in monthly inspections of the construction worksite.
- Participate in monthly Partnership meetings.
- Review site-safety and health programs, and provide recommendations
for improvements, as appropriate.
- Continuously monitor and evaluate the Partnership by making
recommendations and conduct follow-ups, as appropriate for improvement.
- Assist contractors and sub-contractors that do not have adequate
safety and health plans to develop comprehensive, written safety and
health plans. The plans must, at a minimum, incorporate the provisions of
the Luther Midelfort site-specific safety and health plan when so
requested by the contractors and/or subcontractors.
- Provide assistance to those Partnership members conducting OSHA 10 and
30-Hour courses (or other safety and/or health training relevant to the
Luther Midelfort Bed Tower project) when so requested.
- Conduct industrial hygiene monitoring of any contractor periodically
when requested by the contractors, or as determined by the WisCon program.
This could include atmospheric monitoring and noise measurement.
OSHA will:
- Review and compile data provided, and will prepare the annual
Partnership evaluation.
- Participate in monthly Partnership meetings and onsite non-enforcement
walkarounds.
- Review the site’s safety and health program, and provide
recommendations for improvements, as appropriate.
- Provide hazard-identification and technical assistance, as needed.
- Conduct an annual enforcement inspection.
- Conduct focused enforcement inspections, when applicable.
- Assist The Boldt Company with its VPP application process.
- Employee Rights
This Partnership does not preclude employees and/or employers from
exercising any right provided under the OSH Act (or, for federal employees,
29 CFR 1960), nor does it abrogate any responsibility to comply with rules
and regulations adopted pursuant to the Act.
- Term of the OSP
This agreement will terminate on October 31, 2010, which is approximately
two years from the date of the signing.
If OSHA chooses to withdraw its participation in the Partnership, the entire
agreement is terminated.
Any signatory may also propose modification or amendment of the agreement.
If any of the other signatories wishes to withdraw their participation prior
to the established termination date, a written notice of the intent to
withdraw must be provided to all the other signatories.
For Non-Signatory Participants:
For non-signatory participants of this strategic Partnership, OSHA may
terminate the participant’s involvement at any time with written notice.
Additionally, the participant may withdraw their participation from the
strategic Partnership at any time with a written notice of the intent to
withdraw to OSHA.
- Signatures
Signed this day of _____________.
| _______________________________ |
_______________________________ |
Mark W. Hysell
Area Director
Eau Claire Area OSHA Office |
Blaine Tuchscherer
Director of Construction
The Boldt Company |
_______________________________ |
_______________________________ |
John Chapin
WI Safety & Health Consultation Program
UW State Laboratory of Hygiene |
Michael Schultz
Safety Director
J.F. Ahern Co. |
|
_______________________________ |
| |
Tom Andrzejewski
Safety Director
Hunt Electric Corporation |
|
|
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